Homesite Insurance Company v. Norcold, Inc. et al, No. 2:2021cv02167 - Document 49 (D. Nev. 2022)
Court Description: ORDER Granting 48 Verified Petition for Permission to Practice Pro Hac Vice for Attorney Todd M. Foss for Norcold, Inc., The Dyson-Kissner-Moran Corporation, and Thetford Corporation and approving Designation of Local Counsel for Steven Abbott. Signed by Judge Richard F. Boulware, II on 10/24/2022. Any Attorney not yet registered with the Court's e-filng system shall register on the PACER website www.pacer.gov (Copies have been distributed pursuant to the NEF - TRW)
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Homesite Insurance Company v. Norcold, Inc. et al Doc. 49 Case 2:21-cv-02167-RFB-DJA Document 49 Filed 10/24/22 Page 1 of 8 1 2 3 4 5 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA 6 7 8 9 Homesite Insurance Company as subrogee of Traci Marx and Raymond Marx, et al. 10 Plaintiff(s), vs. 11 12 Norcold, Inc., Thetford Corporation, Camping World of Henderson, et al. 13 Defendant(s). 14 ) ) Case #2:21 -cv-02167-RFB-DJA ) ) ) ) ) ) ) ) ) J VERIFIED PETITION FOR PERMISSION TO PRACTICE IN THIS CASE ONLY BY ATTORNEY NOT ADMITTED TO THE BAR OF THIS COURT AND DESIGNATION OF LOCAL COUNSEL FILING FEE IS $250.00 15 ________ lodd M. boss_________ Petitioner, respectfully represents to the Court: (name of petitioner) 16 17 1. That Petitioner is an attorney at law and a member of the law firm of 18 Cokinos | Young (firm name) 19 20 21 Houston Texas J (city)............................. (state)________________ (zip code) ...... 22 23 1221 Lamar Street, 16th Floor (street address) with offices at 713-535-5521 (area code + telephone number) J 77010 a tfoss@cokinoslaw.com (Email address) 24 2. 25 26 27 28 _____ That Petitioner has been retained personally or as a member of the law firm by Norcold, Thetford, and DKM________ to provide legal representation in connection with [client(s)] the above-entitled case now pending before this Court. Rev. 5/16 Dockets.Justia.com Case 2:21-cv-02167-RFB-DJA Document 49 Filed 10/24/22 Page 2 of 8 November 6, 2003 , Petitioner has been and presently is a (date) member in good standing of the bar of the highest Court of the State of_________ Texas (state) where Petitioner regularly practices law. Petitioner shall attach a certificate from the state bar or 3. 2 3 That since i from the clerk of the supreme court or highest admitting court of each state, territory, or insular 5 possession of the United States in which the applicant has been admitted to practice law certifying 6 the applicant's membership therein is in good standing. 7 4. That Petitioner was admitted to practice before the following United States District 8 Courts, United States Circuit Courts of Appeal, the Supreme Court of the United States and Courts 9 of other States on the dates indicated for each, and that Petitioner is presently a member in good 10 standing of the bars of said Courts. 11 Court 12 U.S. District Court, Southern District of Texas June 21, 2007 711306 13 Florida State Courts November 19,2005 18103 Date Admitted Bar Number 14 15 16 17 18 19 5. That there are or have been no disciplinary proceedings instituted against petitioner, 20 nor any suspension of any license, certificate or privilege to appear before any judicial, regulatory 21 or administrative body, or any resignation or termination in order to avoid disciplinary or 22 disbarment proceedings, except as described in detail below: 23 24 None. (State “none” if Petitioner has no disciplinary proceedings, etc.) 25 26 27 28 2 Rev. 5/16 Case 2:21-cv-02167-RFB-DJA Document 49 Filed 10/24/22 Page 3 of 8 1 That Petitioner has never been denied admission to the State Bar of Nevada. (Give 6. 2 particulars if ever denied admission): 3 None. (State “none” if Petitioner has never been denied admission.) 4 5 6 7 8 That Petitioner is a member of good standing in the following Bar Associations. 7. Texas State Bar Association. The Florida Bar. (State “none” if Petitioner is not a member of other Bar Associations.) 9 10 8. Petitioner has filed application(s) to appear as counsel under Local Rule IA 11-2 11 (formerly LR IA 10-2) during the 12 Date of Application past three (3) years in the following matters: (State "none" if no applications.) Title of Court Administrative Body or Arbitrator Cause 13 14 Was Application Granted or Denied None 15 16 17 18 (If necessary, please attach a statement of additional applications) 19 20 9. Petitioner consents to the jurisdiction of the courts and disciplinary boards of the 21 State of Nevada with respect to the law of this state governing the conduct of attorneys to the same 22 extent as a member of the State Bar of Nevada. 23 24 25 26 10. Petitioner agrees to comply with the standards of professional conduct required of the members of the bar of this court. 11. Petitioner has disclosed in writing to the client that the applicant is not admitted to practice in this jurisdiction and that the client has consented to such representation. 27 28 3 Rev. 5/16 Case 2:21-cv-02167-RFB-DJA Document 49 Filed 10/24/22 Page 4 of 8 1 That Petitioner respectfully prays that Petitioner be admitted to practice before this Court 2 3 4 5 6 7 8 Todd M. Foss , Petitioner, being first duly sworn, deposes and says: That the foregoing statements are true. 9 Petitioner’s signature 10 11 Subscribed and sworn to before me this day ofOr Aber DANA HODGES Notary Public, State of Texas Comm. Expires 05-09-2026 Notary ID 3993511 12 13 14 15 16 DESIGNATION OF RESIDENT ATTORNEY ADMITTED TO THE BAR OF THIS COURT AND CONSENT THERETO. 17 Pursuant to the requirements of the Local Rules of Practice for this Court, the Petitioner 18 believes it to be in the best interests of the client(s) to designate 19 Steven Abbott (name of local counsel) Attorney at Law, member of the State of Nevada and previously admitted to practice before the 20 above-entitled Court as associate resident counsel in this action. The address and email address of 21 said designated Nevada counsel is: 22 23 24 25 26 ______________________ 6385 South Rainbow Boulevard, Suite 600______________________ . (street address) _____________ Las Vegas _____________ ,_________ ” " (city) 702-693-4370_________ , (area code + telephone number) Nevada___________ , (state) 89118 , (zip code) steven.abbott@lewisbrisbois.com (Email address) 27 28 4 Rev. 5/16 Case 2:21-cv-02167-RFB-DJA Document 49 Filed 10/24/22 Page 5 of 8 1 By this designation the petitioner and undersigned party(ies) agree that this designation constitutes 2 agreement and authorization for the designated resident admitted counsel to sign stipulations 3 binding on all of us, 4 APPOINTMENT OF DESIGNATED RESIDENT NEVADA COUNSEL 5 6 7 8 The undersigned party(ies) appoints)_______ 1 Steven Abbott_____________ (name of local counsel) his/her/their Designated Resident Nevada Counsel in this case. 9 10 (party's signature) 11 Ryan Roney, General Counsel, Thetford LLC $rt JtleJ 12 13 14 John H. FitzSimons, Senior Vice President The Dyson-Kissner-Moran Corporation 15 (type or print party name, title) 16 CONSENT OF DESIGNEE 17 The undersigned hereby consents to serve as associate resident Nevada counsel in this case. 18 19 esignated Resident Nevada Counsel's signature 20 10303 Bar number 21 steven.abbott@lewisbrisbois.com Email address 22 23 APPROVED: 24 Dated: this 24th day of October, 2022. day of, 20___ . 25 26 UNITED STATES DISTRICT JUDGE 27 28 5 Rev. 5/16 Case 2:21-cv-02167-RFB-DJA Document 49 Filed 10/24/22 Page 6 of 8 STATE BAR OF TEXAS Office of the ChiefDisciplinary Counsel October 17, 2022 Re: Mr. Todd M. Foss, State Bar Number 24040922 To Whom It May Concern: This is to certify that Mr. Todd M. Foss was licensed to practice law in Texas on November 06, 2003, and is an active member in good standing with the State Bar of Texas. "Good standing" means that the attorney is current on payment of Bar dues; has met Minimum Continuing Legal Education requirements; and is not presently under either administrative or disciplinary suspension from the practice of law. This certification expires 30 days from the date, unless sooner revoked or rendered invalid by operation of rule or law. Sincerely. Seana Willing Chief Disciplinary Counsel SW/web P.O. BOX 12487, CAPITOL STATION, AUSTIN, TEXAS 78711-2487, 512.427.1350; FAX: 512.427.4167 Case 2:21-cv-02167-RFB-DJA Document 49 Filed 10/24/22 Page 7 of 8 The Florida Bar 651 East Jefferson Street Tallahassee, FL 32399-2300 Joshua E. Doyle Executive Director 850/561-5600 www.FLORIDABAR.org State of Florida ) County of Leon ) In Re: 0018103 Todd Matthew Foss Cokinos | Young 1221 Lamar St Fl 16 Houston, TX 77010-3039 I CERTIFY THE FOLLOWING: I am the custodian of membership records of The Florida Bar. The Florida Bar membership records indicate that The Florida Bar member listed above was admitted to practice law in the state of Florida on November 19,2005. The Florida Bar membership records also indicate that The Florida Bar member above is an inactive member of The Florida Bar in good standing. The Inactive status of The Florida Bar member above means that The Florida Bar member above is not eligible to practice law in the state of Florida. Dated this 21st day of October, 2022. Cynthia B. Jackson, CFO Administration Division The Florida Bar PG:R12:Inactive CTM-203223 Case 2:21-cv-02167-RFB-DJA Document 49 Filed 10/24/22 Page 8 of 8 Case 4:00-mc-94345 Document 8 Filed on 10/21/22 in TXSD Page 1 of 1 United States District Court Southern District of Texas Certificate of Good Standing I, Nathan Ochsner, Clerk of Court, United States District Court for the Southern District of Texas, certify that the attorney identified below is admitted to practice in this court, and is in good standing as a member of the Bar of this Court. Todd Matthew Foss, Federal ID No 711306 Admission date: June, 21, 2007 Dated October 21, 2022, at Houston, Texas. Nathan Ochsner, Clerk of Court By: Claire Cassady, Deputy Clerk
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